Submission on Draft Water Sharing Plan for the Murrumbidgee River

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Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 Other benefits that medium and high flows bring, are that they provide critical cues for fish and colonial waterbird breeding events, and are important in the dilution of toxicants such as salt and blue-green algae. The CRC for Freshwater Ecology draws the analogy that the riparian and floodplain zones of a river are equivalent to the bark surrounding the woody material of a tree. Therefore harvesting high flows is like ringbarking a river. Water levels in natural river pools should be protected during periods of no flow (River Flow Objectives 1- 2). During dry times some streams stop flowing and form pools that are refuges for aquatic plants and animals. Pumping water from these areas can make it more difficult for many species to recover after a drought. We have included some additional recommendations in this submission which will go further in protecting low flows, and help ensure that fish passage and pools are protected. Water Management Principles in the Act that are particularly relevant to environmental flow provisions in water sharing plans include; protecting and restoring water sources, floodplains and dependent ecosystems (including wetlands), protecting habitats, animals and plants which benefit from water, protecting water quality, minimising cumulative impacts, and applying the principles of adaptive management. Plans can be changed or amended by a Minister’s plan under Section 42(2) of the Act if in the public interest or if specified within the plan. It is evident that there is a flagrant disregard for the Water Management Principles in the Draft WSP for the Murrumbidgee Regulated River Water Source. Most of the rules in the Draft Plan for the provision of environmental water are made “contingent on supplies to water users and are generally tied to the resource availability for water users rather than environmental needs. There also does not appear to be any clearly defined environmental management objectives for the various environmental water accounts and the draft plan does not specify the triggers and rules for the release of this water for environmental purposes” ((Part B, p. 11). The following table (Table 1), prepared by Professor Gary Jones from the CRC for Freshwater Ecology, indicates the percentage of natural flow required to sustain a healthy working river. Table 1: Percentage of Natural Flow Required to Sustain a Healthy Working River % of Natural Flow (for critical indicators) Greater than two-thirds Greater than half Less than half Probability of having a healthy working river HIGH MODERATE LOW Reference: Jones, G. 2002 Setting environmental flows to sustain a healthy working river. Watershed February: 1-2. Scientific evidence indicates that the current flow regimes in NSW are not sufficient to achieve the principle of Ecologically Sustainable Development nor to “protect, enhance and restore water sources, their associated ecosystems, ecological processes, biological diversity and their water quality” (NSW Water Management Act 2000 Section 3 Objects (a) &(b)). Our primary concern is that the Draft WSP for the Murrumbidgee Regulated River Water Source is that it has not been developed in a manner that is consistent with the Act. The environment has not been prioritised as per Section 5(3) & 9(b) of the Act, and the plan is not consistent with the State Water Management Outcomes Plan (SWMOP) as per Section 9. Under the Water Management Act the WSP is to determine the environment’s adequate share of rivers as first priority, basic landholder rights second, and the extractive regime last. As it stands now, the Draft WSP for the Murrumbidgee Regulated River Water Source: - 4 -
Inland Rivers Network and Nature Conservation Council submission: Draft Water Sharing Plan for the Murrumbidgee Regulated River Water Source – 14 June 2002 • Environmental water is contingent on irrigation allocation requirements and as such compromises the protection and restoration of the river’s ecological processes, its dependent ecosystems and native species. • Has no secure environmental water other than that for the maintenance of minimum flows. Environmental Contingency/Health Allowance water is incorporated in the WSP as Class B Supplementary Environmental Water. • Has no methodology for managed environmental releases from stored water. • Stands in isolation from the WSP’s of unregulated catchments, in particular Tarcutta Creek WSP, and identifies no environmental relationships. • Does not identify the ecological values that the Plan is to protect Minister’s Note: (Part B, p.11) IRN, NCC and ACF fully concur with the Minister’s Note on p.11 of Part B. The environmental flow rules, as they stand in this Draft WSP, are extremely complex to the point that they are virtually impossible to understand, review and identify their intended or likely outcomes. It would seem that the intent of this complexity is to reinstate the status quo and entrench the highly inappropriate irrigation practices of the last 30 years – which have led to this river being classified as ‘stressed’. The scientific evidence for this, as compiled in the report “The Murrumbidgee: assessing the ‘health’ of a working river”, jointly commissioned by the Agribusiness Taskforce, DLWC, the EPA and included several members of the irrigation community, is unequivocal. It is these practices that have led to the Murrumbidgee River being brought to the brink of becoming an ecological basket case. The recent listing of the aquatic ecological community in the natural drainage system of the lower Murray River catchment as an endangered ecological community under the Fisheries Management Act 1994 is further evidence of the desperate state of this river. Not only do the dissenting reports cast doubt about the ability of the proposed rules to maintain or improve the ecological health of the Murrumbidgee River, but the WSP also concedes as much. Table 1, Part A of the Plan indicates that the environmental provisions will only make a marginal improvement to flow conditions compared to the1993/94 conditions under the Murray-Darling Basin cap on water diversions. Minister’s Note: (Part B, p.9) The Minister’s Note on p.9 of Part B also correctly identifies, according to our environment representatives, that the environmental water rules are overly focussed on providing flows to wetlands in the middle reaches of the Murrumbidgee River. There are significant wetlands on the lower floodplain of the river, notably the Lowbidgee wetlands, which are not targeted and which presently receive a greatly reduced water supply. Changing Water Regimes and Wetland Habitat on the Lower Murrumbidgee Floodplain of the Murrumbidgee River (Kingsford, R.T. and Thomas, R.F., 2001) documents how over 140 years of water resource development at a catchment and local scale has resulted in the disappearance or degradation of at least 76% of the wetlands. In 1998/99 95% of diverted water reduced the amount of water reaching the Lower Murrumbidgee floodplain by at least 60%. ‘Development’ of the water resource has not been evenly spread out over the 140 years. Kingsford and Thomas estimate that 26% of the floodplain was lost in the period up to 1975. Over the next 23 years from 1975 to 1998 an additional 32% of the original wetland was lost. Of the remaining 42% of original wetland area in the Lower Murrumbidgee floodplain, 44% of the perennial flood dependent vegetation was in poor health or dead and defined as ‘degraded’. Water for other ecological requirements has also not been explicitly addressed by the plan. Furthermore, the mimicking of natural flow variability below Burrinjuck Dam achieved by the 1998 rules is not fully maintained. Recommendations IRN, NCC and ACF are of the opinion that the environmental flow rules for the Murrumbidgee Regulated River are totally inadequate and must be completely rewritten taking the following recommendations into account. - 5 -
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Submission on Draft Water Sharing Plan for the Murrumbidgee River

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